Narrative Statement

0702-EX-PL-2013 Text Documents

Booz Allen Hamilton Inc.

2013-11-06ELS_142660

                                                                         Booz Allen Hamilton Inc.
                                                                          FCC Form 442 Narrative
                                                                     ELS File No. 0702‐EX‐PL‐2013


                                  Narrative Statement

By this application, and pursuant to Section 5.3 (d), (g) and (i) of the FCC Rules, 47 C.F.R. § 5.3
(d), (g), (i) (2012), Booz Allen Hamilton Inc. (“Booz Allen”), respectfully seeks a 24 month
experimental license beginning December 6, 2013, to develop, test and demonstrate prototype
remote sensors with low power communications equipment that will operate in the 902‐904
MHz and 909.750‐921.750 MHz bands allocated for non‐multilateration operations.

The following information is provided in support of this request:

   1) Need for a 24‐month license
      Booz Allen seeks a 24‐month license to accommodate ongoing testing of equipment
      that is expected to change and evolve over this period as a result of Booz Allen’s
      research and development.

   2) Purpose of Operation
      The proposed operation will allow Booz Allen to develop, test, and demonstrate new
      industrial, environmental, infrastructure, and meteorological sensors with wireless
      data infrastructure equipment for emerging applications in safety, security,
      environmental monitoring, and associated research. For example, Booz Allen will
      evaluate low power, low probability of detection and interference wireless methods
      for sensor data communications. Booz Allen will evaluate sensor network data
      capacity, data rates, multi‐path and interference performance, and steered RF signal
      technologies.

       Booz Allen does not seek authority to conduct market studies or provide
       communications services under the requested experimental authority. The
       participants in the test will be advised that: (a) the test is being conducted under and
       experimental authority issued to Booz Allen, (b) Booz Allen is responsible for
       operations, (c) all operations are conducted on a non‐interference basis, and (d) after
       the test is completed, Booz Allen will retrieve and recover all devices that do not
       comply with FCC regulations. Booz Allen understands that the FCC may specify these
       as well as other conditions on its authorization.




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                                                                       Booz Allen Hamilton Inc.
                                                                        FCC Form 442 Narrative
                                                                   ELS File No. 0702‐EX‐PL‐2013

3) Technical Specifications
      a. Power Levels
                i. Transmitter Power Output (“TPO”): 2W peak
               ii. Effective Radiated Power (“ERP”): 3W peak
             iii. Effective Isotropic Radiated Power (“EIRP”): 5W peak
              iv. Necessary bandwidth:
                       1. 20kHz for low data rate operations
                       2. 300kHz for high data rate operations
               v. Modulation: BFSK, QFSK, QAM
              vi. Emissions: F1D, F2D
             vii. Antenna: Omnidirectional
            viii. Notes: Other emission modes may be utilized, but in no event will the
                           emissions extend beyond the frequency bands requested. All
                           power levels will comply with the limits set forth in the FCC’s rules,
                           including those relating to human exposure to radiation.

       b. Antenna Information
          The antennas that would be deployed under this license will not extend more
          than 6 meters above the ground or, if mounted on an existing building, will not
          extend more than 6 meters above the building. If an antenna is mounted on an
          existing structure other than a building, it will be installed in accordance with
          FAA and FCC rules and regulations.

           Omnidirectional antennas will be used in experiments that require uniform
           azimuthal coverage; directional antennas will be used in experiments to
           prevent interference or to limit azimuthal coverage.

       c. Proposed Locations
          Booz Allen seeks authority to conduct its experimental operations at the locations
          specified in the attached table and FCC Form 442. Although it will conduct tests
          primarily indoors at its research and development site at Morrisville, North
          Carolina, Booz Allen also plans to test and demonstrate equipment at these other
          locations. Specifically, Booz Allen seeks authority to operate and demonstrate
          products: (i) at its own premises; (ii) at the premises of entities working under
          Booz Allen's authorization in the design and development of the devices and
          related products; (iii) at trade shows or non‐residential exhibitions; and (iv) at
          non‐residential, business, commercial, industrial, scientific, or medical locations
          during the design, development, and pre‐production stages. Indeed, these
          operations would be consistent with the requirements set forth in Section 2.803
          of the Commission's marketing rules and 47 C.F.R. § 2.803 (2012); see also
          Revision of Part 2 of the Commission's Rules Relating to the Marketing and
          Authorization of Radio Frequency Devices, ET Docket No. 94‐45, Report and
          Order, released Feb. 12, 1997, at 11‐13, 19‐20 (“Marketing Rule Revisions”).

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                                                                    Booz Allen Hamilton Inc.
                                                                     FCC Form 442 Narrative
                                                                ELS File No. 0702‐EX‐PL‐2013


       d. Equipment to be used
          Booz Allen proposes to deploy only a limited number of units which, as noted
          above, would operate at low power levels. Booz Allen expects that it will be
          able to complete its experimentation and demonstration with a maximum of
          10 base units and 25 sensor units per test location. In all experiments, Booz
          Allen will also limit the power, area of operation, and transmitting times of
          these units to the minimum necessary to evaluate the equipment.

4) Restrictions on Operation
   Booz Allen understands that the FCC permits (a) companies to enter into agreements
   and contracts to manufacturer new products and (b) manufacturers to sell—but not
   deliver—products on a conditional basis to wholesalers and retailers. Booz Allen also
   understands that the FCC permits the operation of equipment for, among other
   things, compliance testing, demonstration at trade shows and other exhibitions with
   appropriate notices displayed, and evaluation of product performance and customer
   acceptability at the manufacturer's facilities or at certain non‐residential sites during
   the developmental, design and pre‐production stages. See Marketing Rule Revisions, §
   2.803; Part 15 Revisions, 6 FCC Rcd 1683, 1685 (1991).

   Notwithstanding these general rules, the FCC requires parties to seek authorization to
   use devices that normally require a license to operate or that will be operated at
   residential locations. Such authority may be granted under the FCC's experimental
   rules set forth in Part 5 of the Code of Federal Regulations, 47 C.F.R. Part 5 (2012).
   Accordingly, Booz Allen seeks an experimental license to conduct experimental
   operations permitted under Part 5 of the Commission’s rules. Those rules permit such
   operation provided that: (a) participants are advised that the service or device is
   granted under experimental authority and is strictly temporary; and (b) the devices
   are owned by the licensee.

   Booz Allen does not propose to market, sell, or lease any prototype equipment to end
   users, however. After the experimentation ceases, Booz Allen would recall and
   recover all devices that are not in compliance with FCC regulations. If any different
   treatment becomes necessary during the course of its experimentation, Booz Allen
   will seek separate and additional authority from the agency.

   Booz Allen also recognizes that the operation of any unapproved or unlicensed devices
   under experimentation must not cause harmful interference to authorized facilities.
   Should interference occur, Booz Allen will immediately take reasonable steps to
   resolve the interference, including if necessary discontinuing operation. To that end,
   Booz Allen would advise entities using the equipment that permission to operate the


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                                                                            Booz Allen Hamilton Inc.
                                                                             FCC Form 442 Narrative
                                                                        ELS File No. 0702‐EX‐PL‐2013

   equipment has been granted under experimental authority issued to Booz Allen, is
   strictly temporary and may be canceled at any time. It will also advise entities that
   operation is subject to the condition that the equipment may not cause harmful
   interference. Specifically, Booz Allen proposes to label the equipment conspicuously
   as follows:

                                                 FCC STATEMENT
               Permission to operate this device has been granted under experimental authority
               issued by the Federal Communications Commission to Booz Allen Hamilton Inc., is
               strictly temporary, and may be canceled at any time. Operation is subject to the
               following two conditions: (1) this device may not cause harmful interference and
               (2) this device must accept any interference received including interference that
               may cause undesired operation.
               This device has not been authorized as required by the rules of the Federal
               Communications Commission. This device is not, and may not be, offered for sale
               or sold until the approval of the FCC has been obtained. Thus, the user does not
               hold a property right in the device and may be required to return the device.


   Moreover, Booz Allen submits that its experimental operations are unlikely to cause
   interference. Booz Allen intends to monitor use of the relevant frequencies before
   commencing transmissions, and it will not operate if the frequencies are in use.

5) Public Interest
   Booz Allen submits that issuance of a license is in the public interest, convenience, and
   necessity. Grant of a license will permit Booz Allen to develop innovative equipment
   that will accommodate the communications needs of users.

6) Contact Information
      a. Technical Point of Contact                            b. Legal Contact
         Dr. John C. Swartz, Lead Associate                       Ms. Callie Carr, Lead Associate
         Adv Engineering Acct Group                               Booz Allen Hamilton Inc.
         Booz Allen Hamilton Inc.                                 8283 Greensboro Drive
         511 Davis Drive, Suite 400                               McLean, VA 22102
         Morrisville, NC 27560                                    Office: (703) 377‐4473
         Office:     (919)595‐4825                                Email: Carr_Callie@bah.com
         Facsimile: (919)595‐4825
         Mobile: (919)270‐5074
         Email: swartz_john@bah.com




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                                                           Booz Allen Hamilton Inc.
                                                            FCC Form 442 Narrative
                                                       ELS File No. 0702‐EX‐PL‐2013




                                     LOCATIONS

       16 kilometer radius of                1.6 kilometer radius of
       7000 River Road                       Booz Allen Hamilton Inc.
       Fredericksburg, VA 22407              Virginia Square Office
       (N 38.331835, W 77.575795)            3811 Fairfax Dr.
                                             Arlington, VA 22203
                                             (N 38.882648, W 77.105829)
       32 kilometer radius of                1.6 kilometer radius of
       1771 Felix Canyon Rd.                 Booz Allen Hamilton Inc.
       Flying H, NM 88339                    McLean Office
       (N 33.020755, W 105.113869)           8283 Greensboro Dr.
                                             McLean, VA 22102
                                             (N 38.922708, W 77.231936)
       16 kilometer radius of                1.6 kilometer radius of
       Booz Allen Hamilton Inc.              Booz Allen Hamilton Inc.
       511 Davis Drive, Suite 400            Tampa Office
       Morrisville, NC 27560                 4890 W Kennedy Blvd #475
       (N 35.874524, W78.859994)             Tampa, FL 33609
                                             (N 27.943991, W 82.525855)
       1.6 kilometer radius of               1.6 kilometer radius of
       Booz Allen Hamilton Inc.              Booz Allen Hamilton Inc.
       One Dulles Facility                   Fayetteville Office
       13200 Woodland Park Road              4200 Morganton Rd.
       Herndon, VA 20171                     Fayetteville, NC 28314
       (N 38.955112, W 77.403705)            (N 35.068572, W 78.95341)




13663053.1




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Document Created: 2013-11-06 13:09:26
Document Modified: 2013-11-06 13:09:26

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